Providers are scrambling to make sure they are filing Provider Relief Fund (PRF) reports correctly and have all relevant data to avoid auditing woes or rejected reports.
Consultants and skilled nursing advocacy groups have stepped up to provide guidance on how to submit reports to the newly opened PRF portal — the Health Resources and Services Administration (HRSA) clarified reporting requirements at the beginning of this month from updates the organization released June 11.
Operators that experienced a change in ownership in the last year-and-a-half, or those who were in the middle of a payroll system switch may find reporting requirements particularly challenging, consulting firm BKD CPAs & Advisors told Skilled Nursing News.
“I think [the American Health Care Association, AHCA] has done an excellent job of advocating for the provider community in getting greater clarification. But that’s going to be a real struggle for organizations to pull together that information. Because the guidance has come out retrospectively,” said John Harned, director of life plan communities and CCRCs at BKD.
BKD provides accounting services and financial consultation to members of the skilled nursing and long-term care sector, with a focus on the provider community.
These same operators are closely focused on rebuilding at this point in the pandemic — to operators, rebuilding translates to boosting occupancy and improving census.
“There’s been a lot of angst around how frequently the guidance on [PRF reporting] has changed. It’s a land shift. I mean, whatever level of earthquake you can name, it’s that level of change that is occurring each time they issue these frequently asked questions,” added Harned.
It’s unclear if HRSA will be lenient with operators who don’t have the required data for reimbursement, Harned told SNN.
The most important PRF reporting change relates to the availability and reporting of funds timeline — previously, all PRF payments $10,000 or more (cumulatively) needed to be used by June 30 or returned to the U.S. Department of Health and Human Services (HHS) regardless of when they were acquired.
Now, the timeline to use such funds is tied to when they were received, and is only for payments $10,000 or more in the aggregate.
For example, those who received PRF payments between April 10 and June 30, 2020 had until June 30 of this year to use their funds. These providers need to submit their first report between July 1 and Sept. 30 of this year; recipients have a 90-day window to complete reporting.
“Really, the July 1 FAQs were just clarifications of what they’d already been hinting at,” said Ally Jackson, senior manager at BKD during a webinar July 13.
July guidance also says reporting requirements now apply to recipients of the Nursing Homes Infection Control Distribution, formerly Skilled Nursing Facility and Nursing Home Infection Control Distribution.
PRF Reporting Guidance
Along with Jackson, Springfield, Mo.-based BKD’s webinar was led by Brian Pavona, partner; and Catherine Gilpin, managing director.
The presentation detailed reporting periods and the deadline to use funds in a chart for providers before jumping into a Q&A session for listeners.
Questions revolved around reporting quarterly lost revenue, if COVID-related expenses will be accepted, audit thresholds and — crucially — if and when providers would hear back from HRSA.
“After submission, HRSA isn’t going to necessarily approve or accept your submission and say ‘oh, I agree with that, I think it’s good.’ You’re going to submit it, and you’re not going to hear anything,” Gilpin said during the webinar. “No news is good news.”
Gilpin added that there’s typically a three-year document retention period for federal grant funds from the date a report is submitted. Providers should retain all documentation supporting submissions during that time.
A switch to quarterly reporting for lost revenue is considered a major boon for providers, BKD presenters said, as they’re easier to justify rather than a submission covering a longer timeframe.
“What a lot of organizations did when they heard this news and started to think about it was to take a step back and think about a sensitivity or impact analysis; does this result in an increase in reimbursement of the lost revenues for organizations, and many of them have indicated that they’re likely to believe they’re going to retain more because of that. That’s really good news,” said Pavona.
Submitted COVID-related expenses, HRSA said, need to have helped prevent, prepare for or respond to COVID-19. The government entity will accept “regular accounting methodologies,” BKD presenters said, but further documentation might need to be provided if the provider is audited.
The threshold for a single audit is $750,000 in expenditures, Jackson added.